CNL anticipates that there may be situations where the cleanup of low-level radioactive waste (LLRW) is not practical, reasonably achievable or desired.
The PHAI is also voluntary and each property owner may choose whether or not, or the extent to which, they participate.
CNL offers choices to property owners and maintains a Special Circumstances Protocol to address situations where removing the waste is not practical or possible.
In certain situations there may be specific constraints that prevent CNL from carrying out a full remediation on a property with waste.
Property-owner directed constraint when an owner chooses to leave historic waste on their property in order to preserve a special feature.
Access constraint where an owner denies CNL access to all or part of a property
Social/heritage constraint on features of significance to the community, e.g. mature trees and historic buildings
Environmental constraint on features like endangered species such as butternut trees and areas
of natural scientific importance or environmental sensitivity
Physical constraint exists when removal of the waste will cause instability in a structure or other features of the property
Operational constraint where the waste is very deep it would not make sense to dig that deep to remove it.
The Special Circumstances Protocol has been developed for situations like these where the cleanup of waste is not practical, reasonably achievable or desired.
CNL will consult with Atomic Energy of Canada Limited (as the representative of the Government of Canada) before applying a special circumstances exemption to a property and will seek the approval of the Municipality of Port Hope if an exemption is to be applied to a municipally owned property.
To support the application of a special circumstances, CNL will conduct a risk assessment to confirm that the continued presence of historic low-level radioactive waste on the property is protective of human health and the environment. However, if a property owner denies CNL access to part or all of their property or chooses to leave historic waste on their property, the risk assessment will not be conducted.
In cases where CNL opts to apply special circumstances, the property owner will be advised during the design phase, prior to the owner signing the Remediation & Restoration Agreement, or at the time the constraint is identified, which may be during PHAI work on the property.
Contact us to learn more about choices for property owners and Special Circumstances.
